Solar and wind projects under construction spend hundreds of billions of dong on equipment — a large share being input VAT. A proper VAT refund recovers significant cash flow before the project generates a single kWh; a flawed dossier leaves money parked at the tax office for months. The VAT Law 48/2024/QH15 (effective 1 January 2026) maintains the refund mechanism for investment projects.
Refund eligibility conditions
New investment projects in the investment phase (not yet operating, no revenue yet) may claim refunds of input VAT on goods and services purchased for the project, provided: full business and tax registration, lawful VAT invoices for purchases, bank transfers for invoices at or above the regulated threshold, and separate accounting of the project’s input VAT.
The key point: input VAT is refundable only when used for a new investment project during the investment phase — costs after operation begins are deducted through normal periodic filings, not refunded as investment-phase VAT.
Dossier and refund process
Refund dossiers go to the directly managing tax authority, including the claim form, invoice schedules and investment-project proof (investment registration certificate or policy-approval decision). Tax authorities classify cases as refund-before-audit or audit-before-refund based on taxpayer risk — compliant taxpayers get refund-before-audit, shortening time to cash.
Processing times follow tax administration law (Tax Administration Law 108/2025/QH15, effective 1 July 2026); actual speed depends heavily on dossier quality — clean dossiers, complete invoices and clear separate accounting keep the process flowing.
Four mistakes that stall refund dossiers
One, unlawful or non-compliant invoices (missing data, wrong rates). Two, cash payments for invoices requiring bank transfer. Three, no separate accounting of project input VAT versus other business — the authority cannot isolate project VAT. Four, claiming investment-phase refunds after revenue has arisen. Each mistake returns the dossier or triggers pre-refund audit — costing months.
This article has been quality-reviewed by the FLAW AI Legal Council.
Frequently Asked Questions
Can a solar project under construction get VAT refunds?
Yes. New investment projects in the investment phase (not operating, no revenue) may claim input VAT refunds on project purchases with lawful invoices, bank transfers as regulated, and separate project VAT accounting. This is a key cash-flow recovery source before generation starts.
When does refund-before-audit apply?
Tax authorities classify by taxpayer risk: compliant taxpayers get refund-before-audit, shortening time to cash. High-risk taxpayers face audit-before-refund. A clean compliance history is the fastest route to refund-before-audit.
What most commonly gets VAT refund dossiers returned?
Four common mistakes: unlawful invoices; cash payments for invoices requiring bank transfer; no separate project VAT accounting; claiming investment-phase refunds after revenue arose. Each returns the dossier or triggers pre-refund audit.